7th Circ. Reverses Restitution Order In ABN Bribery Case

Law360, New York (January 19, 2012, 6:51 PM EST) -- The Seventh Circuit on Thursday struck down a $16.2 million restitution order against the one-time head of an Illinois-based security firm convicted in a bribery scheme that bilked a former banking unit of ABN Amro Holding NV out of $45 million.

Unlike a prison sentence or a forfeiture order, criminal restitution can only be based on a victim's loss, not the defendant's approximate gain, a three-judge panel weighing Armando Navarette's appeal said.

Comparing the prices of Navarette's company with those of a replacement company that LaSalle...
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